409 results for “disallowance”+ Section 44clear
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disallowance under section 40(a)(i) is called for. 43. The Assessing Officer, however, held that the services fall within the scope of “fees for technical services” (FTS) as defined in Explanation 2 to section 9(1)(vii) and since the assessee is a resident, tax should have been deducted under section 195. The DRP affirmed this view relying